MARCH 15, 2001

Good day Mr. Chairman, I am Captain Duane Woerth, President of The Air Line Pilots Association, International (ALPA). ALPA represents the professional interests of 59,000 pilots who fly for 49 airlines in the United States and Canada. We appreciate the opportunity to appear before you today to discuss the very complex issues of flight delays and proposed solutions to the problem.

The summers of 1999 and 2000 have proven the forecasts for increased traffic and potential for gridlock in the ATC system to be quite accurate. The aviation community and travelling public after 1999 believed that the air traffic control delays could not have been worse and that positive steps needed to be taken to prevent a repeat performance. ALPA believes the FAA took a very positive step with the Spring 2000 (S2K) Initiative. Without it, in the summer of 2000, things could well have been worse. This work continues under the name S2K+1.

Spring 2000 set up a daily collaborative planning process that is designed to allow significantly better response to severe weather situations and other system constraints. Its goal is to deploy the tools and processes that will provide consumers with the predictability, accountability, and reliability they expect from the national air transportation system. The list of technologies and tools in use include Flight Schedule Monitoring, the Collaborative Convective Forecast Product, Departure Spacing Program, Coded Departure Routes, the National Playbook (deals with severe weather reroutes), Military Special Use Airspace Access, and Post Event Tools, to name a few. Many more innovative technologies are under development and their testing and deployment needs to be accelerated.

Spring 2000 is a much-needed tactical approach to managing the National Airspace System (NAS) on a real-time basis and it is clear that this initiative must be continued indefinitely. We urge that the FAA’s Operations and Maintenance budget be increased to fund this new process for managing the daily operation of the system. We expect that the FAA will shortly change the name of this initiative to properly reflect that it is an integral part of the NAS.

The issue of Air Traffic Service delays, and their relationship to system safety, is an issue in which ALPA has a deep and lengthy history of interest. The air traffic control system has become a convenient target and a scapegoat for much deeper systemic problems. Air traffic control is often blamed for delays it is compelled to implement to maintain the safety of the National Airspace System, but are actually caused by problems outside the control of air traffic.

Keep in mind that delays are merely symptoms or manifestations of larger problems or uncontrollable situations in the National Airspace System. Delays can come from a number of sources-the two most prominent are airspace and airports – although it is in the interfacing of these two elements that seems to produce most delays. The causes of delays are primarily weather, scheduling that is based on optimum weather scenarios, the hub and spoke system, usable runways, gate availability, and choke points caused by airspace saturation. With that background, I need to point out that there are airspace sectors throughout the system that sometimes are at absolute maximum capacity even without the influence of other previously mentioned factors such as weather. When these other external elements are added, the system just collapses.

Was the Summer of 2000 worse than the Summer of 1999? In 2000 the eastern third of the nation experienced more severe convective weather, approximately three times the average number of days. That was the primary cause of the delays. In addition, the airlines scheduled a record number of flights, which increased the potential for greater delays. Our understanding is that while more flights took place, and more passengers were moved, there were a greater number of delays.

It is clear that at certain times on certain days scheduled traffic at the hubs is at absolute capacity. Most of the time Visual Meteorological Conditions (VMC) prevail and airline schedules are based on VMC airport arrival rates. When the weather drops below visual minimums, especially at airports with limited instrument landing capability, the impact begins to ripple through the system. When an airport must restrict use of its runways because spacing or configuration precludes their use under Instrument Meteorological Conditions (IMC), then the airport acceptance rate falls and departure rates are cut. This results in ground delays at departure airports, inbound airborne aircraft holding, and then ground delays for departures at the arrival airport where planes are waiting to take off – it’s like dominos. In the summer thunderstorm season, when severe convective weather activity develops, it often results in airports being closed to all traffic for an extended time, thus creating havoc in the system. The Spring 2000 initiative has shown that tactical management can relieve some of the problems, but there is no total solution to mitigating the impact of severe weather, except not to fly into or near it. Maintaining the safety of the system is the guiding principle for all decisions.

We have possibly created a false level of expectation for the flying public by promising that people can fly where they want to, when they want to. To satisfy this demand we have created a scheduling system that requires more aircraft to operate at the same time than the system can efficiently handle, even on the best of days. The schedule unrealistically projects more aircraft into an airport in a one-hour time period than the airport can accommodate. Competition compels airlines to schedule a maximum number of departures at the top of the hour, so the real crunch occurs in a thirty-minute block. Therefore, whenever uncontrollable events like weather occur the system collapses from its own weight.

To maintain a semblance of on-time operations, the time between city pairs has been increased, in some cases dramatically. An example is the Washington – New York shuttle schedules that display considerably different times for the same route depending on the departure time. At least this schedule is realistic and the travelling public has correct information on which to plan.

The pressure continues to be put on the ATC system. A while ago, it was mandated that the four slot-controlled airports permit more flights. Allowing more flights at these airports will aggravate the situation, unless arrival and departures are mandated to the slack periods. However, these times may be less desirable by the travelling public.

Our pilots are every bit as concerned about these delays as you and the flying public are. We too hear the stories of excessive delays for no apparent reason. These experiences, combined with some of the less thoughtful capacity initiatives the FAA has tried, have only served to reinforce our suspicions that capacity is being emphasized to the detriment of safety. We still have the safest system in the world, but our confidence in it is challenged by what we experience on a daily basis.

Several of the FAA’s innovative capacity enhancements have been aimed directly at this aspect of the equation – how can we get more airplanes on the concrete in a given amount of time? Air traffic control has very specific, safety based, restrictions on runway utilization. These air traffic control standards are designed to ensure the separation of an aircraft and its passengers from other aircraft thus establishing a safety standard. We cannot afford to lessen these standards without full and open testing and evaluation. Capacity critical initiatives must be backed with data that proves that the minimum level of safety is maintained and hopefully enhanced. The FAA clearly has the burden of proof.

Sometimes forgotten, or underestimated and overlooked, is the real impact that the FAA’s punishment-based ATC system has on delays. With the emphasis by the FAA on disciplinary programs designed to assess blame/fault, rather than educational-based programs designed to determine cause and solution to the problem, the FAA has created a built-in delay-producer. The FAA grades itself on the number of controller and pilot mistakes it detects – Operational Errors and Pilot Deviations. The pilot or controller involved is subject to administrative disciplinary action if it is determined either is at fault. Error detection in the enroute portion of the program is automated (Quality Assurance Program, or "snitch patch") and, until recently, there was no discretion available for "no harm, no foul" situations. Because of this, controllers add miles in buffers to existing separation standards to ensure they won’t have a "deal." Pilots are equally paranoid and mistrusting of anything the FAA suggests because most of their interface with the FAA is when Flight Standards is pursuing an enforcement case which could result in a suspension of a pilot’s license and loss of income. This does not contribute to a healthy environment on either side of the microphone, and results in additional questioning, readbacks and pilot rejection of controller clearances that only serve to further clog the system.

One recent decision by the FAA indicates some change in the investigative process for controller errors. In the past, operational errors that violated separation standards subjected the controller to relief from duty, remedial training and loss of certification, regardless of severity of the incident. The FAA now will assess the safety loss from an error, and, provided 80% of the separation standard was maintained, will designate it as a technical violation and will treat it more leniently. The resulting technical violation will be recorded on a separate sheet in the controller’s training folder and be discarded after twelve months. The FAA will keep track of both technical errors and operational violations.

The error versus technical violation approach supports shifting the focus to preventing and managing errors and recognizes there are minor deviations that do not jeopardize safety. While pilots have some leeway and can deviate from airspeed and altitude within accepted limits, controllers could not. This methodology recognizes that human error can not be avoided by disciplining operators and that sanctions, threats and fear have only a very limited effectiveness, and do more harm than good to morale, self respect and to the individual’s and organization’s sense of justice. We realize that another reason for this method of operation is to have the controllers apply the current standards without adding margins to protect their careers, thereby adding some efficiency and capacity to the system. This may be an added bonus to the system. We believe that the FAA cannot reasonably expect to eliminate all the personal margins controllers may use to prevent errors, but that the new guidelines may improve the work environment.

Another significant element of any program truly designed to enhance safety and efficiency is an ability to collect accurate data concerning incidents that occur within the system. The only realistic way to do this is to establish a "no-fault" reporting system for both pilots and controllers. This program must have the objective of investigating for safety purposes – investigate incidents to determine why they happened, and what can be done to ensure they don’t happen again. The individuals involved must be able to participate freely, without fear of repercussions, in order for a system like this to work. Several programs that could be used as models already exist – the American Airlines ASAP program that is currently being expanded to all air carriers, the NASA Aviation Safety Reporting System, and the US Airways Altitude Deviation Reporting program. A number of airlines are also currently in the process of setting up Flight Operations Quality Assurance (FOQA) programs that are designed to use automated aircraft performance data to improve operational safety and aircraft operating procedures. A program must have integrity and credibility with both the pilots and controllers to be effective. To be able to work on the root causes of deeply imbedded systemic problems it is essential that the program have accurate, safety-oriented data to work with. Only through such a program, with guaranteed immunity from all but intentional rule violations will we ever be able to identify and correct potentially catastrophic problems.

Environmental concerns have a great impact on the aviation industry. Noise restrictions constrain arrival and departure routes thereby exacerbating the delay problem. The airlines and manufacturers have spent millions of dollars designing newer, quieter aircraft. Pilots are compelled to fly highly complex procedures at less than optimal operational performance standards to comply with ground based constituent concerns. The industry has done all it can do to alleviate these complaints. There must be a paradigm shift in the public to understand that part of the cost of reducing system delays may be the more efficient use of terminal airspace and aircraft performance capabilities – and that may result in an aircraft overflying someone’s house. This wholesale acquiescence to environmental concerns may have to be amended if we are to thoroughly address the entire scope of the delay problem.

For example, Phoenix International Airport is the busiest two runway operation in the U.S. but is confined to a single departure stream because the departures on both runways 8 R and L must fly up the dry river bed that is roughly between the two straight-out departure paths. Pilots are required to establish visual separation from the previous departure in order for the departure rate to be maintained at an acceptable level. In normal operations, when there is no weather or other factors causing departure delays, the airport is forced to operate in a very inefficient manner. When weather is a factor, the delays are compounded and the controllers have no way to expeditiously get the backlog of departures airborne. In reality, the environmental delay is part of the airport’s normal operation.

Resectorization of enroute airspace can lead to some efficiency gains by eliminating some of the traffic flow choke points referred to earlier. At this time the FAA has identified nine choke points and if traffic increases as predicted the number of choke points will increase accordingly. Initial evaluation of en route airspace resectorization proposals being touted by a number of potential contractors seems feasible – and they may well be, but not quickly. In fact, RTCA has Special Committee 192 looking into this concept, among others, to better utilize our national airspace. The recommendations that will be forthcoming from this Committee will result in better management of our scarce airspace resource but will not be possible without allowing the FAA to consolidate facilities and that will require some tough political decisions.

Additionally, the solution to resectorization in the past has been to divide the airspace, assign frequencies and train controllers. However, the FAA has stated that not enough frequencies are available to accomplish the needed sectorization. The problem of a lack of needed frequencies was predicted some time ago and it is coming to pass. The FAA has been pursuing solutions and has requested RTCA’s assistance to produce an operations document to characterize an operational concept and associated requirements for an integrated digital air/ground voice and data system in the U.S. National Airspace System. We fully support the work of RTCA Special Committee 198 and anticipate that the target date for a document of September 2001 will be met.

ALPA's view is that construction of new runways, taxiways, terminals and other infrastructure is equally as important as the development of additional ATC capacity initiatives. And, in fact, many of the top 100 airports are planning for new and extended runways and other facilities to create more capacity. Some considerations for new runway construction are: runways must be built where the traffic demand is forecast to be highest; must be fully usable by appropriate aircraft (appropriate length and navigational aids); must have flyable noise restrictions; must have ready access to the parking and gate areas, and must be usable throughout the day and night.

Obviously, the new runways are built to expedite and increase departures and arrivals. However, it should be noted that new runways, depending on the airport location, could fail to meet the design potential because of the airspace above the airport could be saturated with enroute traffic. The departures have to fit into the flow and with the constant stream of enroute traffic, requested cruise altitudes, or any operationally acceptable altitude, may not be available which will cause departure delays. Resources must be made available to expedite resectorization, frequency availability, reduced vertical separation above flight level 290. Construction of new runways and modernization of our airspace system must be undertaken simultaneously if we are to truly address the growing problem of delays.

ALPA’s motto is Schedule With Safety. We will continue to champion that standard and will work with the FAA and members of the aviation industry to develop initiatives that will improve efficiency, as well as maintain and hopefully improve the safety of air operations. A fundamental objective that is not always demonstrated when changes are proposed is that any decrease in existing separation standards or any capacity enhancement procedure must result in meaningful increases in capacity to be justified. The costs and benefits are not always defined and backed by credible study. New procedures must not require pilot or controller actions that cannot always be complied with and pilot responsibilities must be properly integrated with all other flight deck duties. All capacity initiatives must be proven to maintain or increase the safety of air operations and good test and evaluation data is needed to support the implementation of new technologies and procedures. We can accept nothing less.

No pilot organization wants capacity controls placed on the air traffic system. Fewer airplanes means fewer jobs. At the same time, we cannot schedule twenty aircraft to depart one airport at the same time and not have significant delays. If market forces dictate those departures, something will have to yield. The La Guardia Airport experience after slot restrictions were relaxed demonstrates that we can not have unlimited service at physically limited airports. Just as is the case when new runways and airspace changes are proposed, a public debate on scheduling practices is necessary.

In closing, I want to thank you for giving me this opportunity to address this most complex of topics. This is one of, if not the top priority for ALPA, and you will be hearing much more from us in the future about the need to modernize our National Airspace System. I would be most happy to answer any questions.